Interpretation Response #98-0215

Interpretation Response Details

OCT 27, 1998

Mr. Paul Bomgardner                            Ref. No. 98-0215
American Trucking Associations
220 Mill Road
Alexandria, VA 22314-4677

Dear Mr. Bomgardner:

This is in response to your letter regarding the requirements for carrier information contact specified in 49 CFR 172.606, under the Hazardous Materials Regulations (IDv.1R; 49 CFR Parts 171-180). You enclosed two (2) photographs of an inspection plate attached to a motor vehicle.

The motor carrier requirements prescribed in 49 CFR 396.17 prescribe an inspection report for commercial motor vehicles, including trailers and semi-trailers. You stated that many motor carriers choose to comply with this requirement by attaching a plate to the motor vehicle which contains information required in an inspection report, including the name address of the motor carrier, and may include the motor carrier's telephone number. You asked if the requirement in 49 CFR 172.606, for marking the carrier's telephone number on a motor vehicle, can be met by display of the carrier's telephone number on an inspection plate, as shown in the enclosed photographs.

The answer is no. The provisions in 49 CFR 172.606 require that the telephone number (for carrier notification and information contact) of the motor carrier must be marked on the motor vehicle on the front exterior near the brake hose and electrical connections, or on a label, tag, or sign attached to the motor vehicle near the brake hose or electrical connections. is shown in the enclosed photographs, the inspection plate on the vehicle is displayed on the side and not near the brake hose or electrical connections. Therefore, such display do not meet the requirements in 49 CFR 172.606.

I hope this satisfies you inquiry.

Sincerely,

Delmer F. Billings Chief,
Standards Development
Office of Hazardous Materials Standards

172.606

Regulation Sections